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GILTI Conscience

GILTI Conscience

De: Skadden Arps Slate Meagher & Flom LLP
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This is GILTI Conscience: Casual Discussions on Transfer Pricing, Tax Treaties, and Related Topics, a podcast from Skadden that invites thought leaders and industry experts to discuss pressing transfer pricing issues, international tax reform efforts, and tax administration trends. We also dig into the innovative approaches companies are using to navigate the international tax environment and address the obligation everyone loves to hate. If you like what you’re hearing, be sure to subscribe in your favorite podcast app so you don’t miss any future conversations. Skadden's tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. Additional information about Skadden can be found at skadden.com. GILTI Conscience is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. Skadden’s tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.Copyright 2026 Skadden, Arps, Slate, Meagher & Flom LLP Ciencia Política Economía Finanzas Personales Política y Gobierno
Episodios
  • The Evolution and Impact of the CWI Standard

    The Evolution and Impact of the CWI Standard
    Mar 25 2026

    In this episode of "GILTI Conscience," Mike McDonald, one of the architects of Internal Revenue Code Section 482, joins Skadden’s Nate Carden, David Farhat, Eman Cuyler and Stefane Victor for an in-depth discussion of the "commensurate with income" (CWI) standard. The panel explores the legislative history and intent behind CWI, its complex relationship with the arm’s length principle and the evolution of regulatory approaches.

    💡 Featured Guests 💡

    Name: Mike McDonald

    What he does: Mike spent 16 years at the U.S. Department of the Treasury in the business and international tax division, followed by a career as managing director of international tax and transactions, transfer pricing at Ernst & Young. He was a drafter of the Section 482 transfer pricing regulations, including 482-7.

    Words of Wisdom: "The fact that, to the extent that a ‘pure hindsight rule’ is going to be applied, then there is going to be wicked double taxation, because the other side doesn't have to respect it.”

    Connect: LinkedIn

    Connect with Skadden

    ☑️ Follow us on X and LinkedIn.

    ☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify or your favorite podcast app.

    ☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at eman.cuyler@skadden.com.

    GILTI Conscience is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. Skadden’s tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. The insights and views presented in GILTI Conscience are for general information purposes only and should not be taken as legal advice for any individual case or situation. The information presented is not a substitute for consulting with an attorney, nor does tuning into this podcast constitute an attorney-client relationship of any kind.
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    38 m
  • Navigating Pillar Two: Side-by-Side, Safe Harbors and the Future of Global Tax Cooperation

    Navigating Pillar Two: Side-by-Side, Safe Harbors and the Future of Global Tax Cooperation
    Feb 26 2026
    Dive into the complexities of international tax reform as Skadden’s David Farhat, Patrick O'Gara, Loren Ponds and Stefane Victor, along with Pascal Saint-Amans — former director of the OECD’s Centre for Tax Policy and Administration — unpack the latest developments in Pillar Two and the Side-by-Side framework. This episode explores how new safe harbors, QDMTTs and evolving global agreements are reshaping the landscape for U.S. and multinational corporations and the practical challenges ahead. Whether you’re a tax professional or just curious about global policy shifts, this discussion offers a front-row seat to the debates shaping tomorrow’s tax world.💡 Featured Guests 💡Name: Pascal Saint-AmansWhat he does: Pascal served as director of the Centre for Tax Policy and Administration at the OECD, where he played an instrumental role in promoting transparency. He is CEO of Saint-Amans Global Advisory, which supports governments, international organizations and business on economic and fiscal issues.Organization: Saint-Amans Global Advisory (SAGA)Words of wisdom: “What really matters in the long game – if you're in the long game – is trying to reduce the tax competition, keeping the infrastructure and surviving maybe for a few more months until November where there may be an election in the. U.S, or later on, where you may have changes and people are more sympathetic to the approach.”Connect: LinkedInConnect with Skadden☑️ Follow us on X and LinkedIn.☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify or your favorite podcast app.☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at eman.cuyler@skadden.com.GILTI Conscience is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. Skadden’s tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. The insights and views presented in GILTI Conscience are for general information purposes only and should not be taken as legal advice for any individual case or situation. The information presented is not a substitute for consulting with an attorney, nor does tuning into this podcast constitute an attorney-client relationship of any kind.
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    42 m
  • From GILTI to NCTI: Unpacking the 2025 Tax Overhaul

    From GILTI to NCTI: Unpacking the 2025 Tax Overhaul
    Nov 13 2025
    This podcast’s title hasn’t changed, but on the international tax stage GILTI is converting to the new CFC-tested income (NCTI) regime.That’s just one shift brought about by the One Big Beautiful Bill that Congress passed on July 4. Skadden colleagues Loren Ponds, Eric Sensenbrenner and Paul Oosterhuis break down the bill’s implications in this conversation with David Farhat and Stefane Victor. The panel explores the legislative process, the impact of dropped provisions such as Section 899 and key planning considerations. Tune in for their insights about how corporate stakeholders can navigate the new landscape.💡 Featured Guests 💡Name: Eric SensenbrennerWhat he does: Eric represents clients on a broad range of U.S. and international tax matters, with a particular emphasis on transactional tax planning in the international context.Organization: SkaddenWords of wisdom: “FDII is now becoming a much more interesting and much more robust tool for attracting investment, both for multinationals thinking about bringing assets back as well as perhaps for inbound investment as well.”Connect: LinkedInName: Loren PondsWhat she does: Loren leverages her extensive tax policy experience to provide strategic counsel to clients across industries on a variety of legislative and regulatory issues.Organization: SkaddenWords of wisdom: “I can speak from experience working on the Hill: When you think you're gifting taxpayers something in a provision, and all you get is pushback, it becomes very easy for that provision to disappear from the final bill, particularly when we're talking about the cost, in addition to the poor reception.”Connect: LinkedIn Name: Paul OosterhuisWhat he does: Paul is an internationally recognized senior tax practitioner with extensive experience in cross-border mergers and acquisitions, post-acquisition integration, spin-offs, internal restructurings and joint ventures.Organization: SkaddenWords of wisdom: “From my perspective, maybe the Trump administration should be talking to those countries about being more lenient in allowing U.S. companies to bring back their IP. Maybe they could get breaks on their tariffs, for example, if they decided to suspend their rules on U.S. companies bringing back their IP.”Connect: LinkedIn Connect with Skadden☑️ Follow us on X and LinkedIn.☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify or your favorite podcast app.☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at eman.cuyler@skadden.com.GILTI Conscience is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. Skadden’s tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. The insights and views presented in GILTI Conscience are for general information purposes only and should not be taken as legal advice for any individual case or situation. The information presented is not a substitute for consulting with an attorney, nor does tuning into this podcast constitute an attorney-client relationship of any kind.
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    48 m
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